Unless otherwise defined, all capitalised terms herein shall have the same meaning as the T&Cs.
Golden Equator Capital Pte. Ltd. and its affiliates (“we”, “us” or “our”) respect the privacy rights of our users (“you” or “your”) and are strongly committed to protecting your privacy. This Privacy Policy aims to give you information on how we collect, process, use, disclose and retain your personal information through GE360 and all Services.
This Privacy Policy is based on the Personal Data Protection Act 2012 of Singapore (as may be amended, supplemented or otherwise modified from time to time, the “PDPA”) and all the associated regulations and guidelines as may from time to time be issued by the Personal Data Protection Commission of Singapore (the “PDPC”).
Notwithstanding the above, we will take steps to comply with all applicable laws with regards to data privacy, including where local laws are more stringent than this policy. For the purposes of this Privacy Policy, the term “applicable laws” shall mean applicable laws, regulations, codes of practice, guidelines, or rules as may be amended, supplemented or otherwise modified from time to time. If you are a European Union resident, please also refer to our General Data Protection Regulation Privacy Statement, which can be found here.
Please review this Privacy Policy in its entirety carefully before using GE360, or otherwise providing us with any of your personal information. This Privacy Policy applies in conjunction with any other policies, notices, contractual clauses and consent clauses that apply in relation to the collection, use and disclosure of your personal information by us, including in any investment management agreement. Specifically, this Policy supplements but does not supersede nor replace any other consents which you may have previously provided to us nor does it affect any rights that we may have at law in connection with the collection, use, disclosure and/or retention of your personal information.
Consent
We had notified or will notify you of the purpose for collection, processing, usage or disclosure of your personal information before we collect, process, use or disclose such personal information respectively, including through the use of this Privacy Policy. By using and continuing to use GE360, you consent to the collection, processing, usage and disclosure of your personal data for the purposes set out in this Privacy Policy.
Under certain circumstances, we may deem that you have provided consent when you voluntarily provide your personal information for specific relevant purposes. For example, when you had provided your name and contact information and thereafter requested for access to GE360, it is deemed that you have provided consent in relation to the creation of a GE360 account.
We may also rely on exceptions to the need for consent under certain circumstances such as the following:
- Such personal information is publicly available;
- Such personal data is disclosed to us as part of another person’s or entity’s contractual obligations or otherwise by contractual necessity; and
- Such personal information is required for debt recovery from you or another person to us.
Information We Collect
We may collect and process certain types of personal information. “Personal information” is data that relates to you and can (on its own or in combination with other information) identify you as an individual, whether true or not. It does not include data that has been aggregated or made anonymous whereby you can no longer be identified using means reasonably available to us.
Personal information includes, among other things, personal information that you voluntarily provide on this website, which may include your:
- Registration information: name; address; e-mail address(es); telephone number(s); date of birth; gender; race; nationality; and passport number;
- Contact information: residential, mailing or billing address(es); e-mail address(es); and telephone number(s); and
- Portfolio and other Financial information: bank account, or other financial information in relation to the portfolio that we are managing on your behalf,
and any other types of information that you choose to provide to us or that we may collect about you through our provision of any Services or your transactions with us in general.
In addition, we may also collect personal information provided by other organisations such as your employer, company or third-party sources (including other entities we believe you have authorised to provide such personal information for and on your behalf, such as business partners, unaffiliated third-party social media companies, data brokers and analysts (via data analytics tools or otherwise), or other information providers, or other commercially and publicly available and legitimate sources as permissible by applicable law).
We also may collect information about you that is not personal information, which may include anonymised or aggregated information, intellectual property or other company information shared with us, from your use of the Services or otherwise. Where necessary, we may combine this information with personal information or other information that we receive from or about you to provide the Services you require in the manner set out below, which combination of such information possibly could be used to identify you personally.
How We Collect, Use and Process Your Personal Information
We may collect, use and/or process your personal information for the following purposes:
- Registering for a GE360 account;
- providing you with GE360 and its Services;
- carrying out your instructions or responding to your enquiries, requests for information submitted by your or on your behalf;
- administering and managing our relationship with you;
- for any logistical or administrative purposes in connection with any of our Services, including informing you or any updates or changes to any Service;
- complying with applicable law or in response to a subpoena, court order, government request, or other legal process for or in connection with litigation, arbitration, mediation, adjudication, government, or internal investigations, or other legal or administrative proceeding;
- protecting, enforcing and/or complying with our contractual, legal rights and/or obligations, as applicable;
- operating and maintaining GE360 and related systems and carrying out our business operations or internal protocols and policies properly including to ensure the safety and security of our users, representatives and all relevant persons in both physical and online environment, including the prevention of fraud, abuse, or other illegal or prohibited activities; and
- for any other incidental or ancillary purposes related to or in connection with the above, including audit requirements and carrying out market-related, evaluative, or similar research and analysis to review, develop, improve or enhance GE360 or our other Services.
Disclosure of Personal Information and Other Information
We may disclose your information, including personal information:
- to our affiliates, where they are directly or indirectly involved in the provision of Services;
- where applicable laws or regulations require such disclosure, such as producing relevant documents or information for the compliance with a subpoena, court order, government request, or other legal process, whether in connection with litigation, arbitration, mediation, adjudication, government, or internal investigations, or other legal or administrative proceeding;
- where such disclosure is required for performing obligations in the course of or in connection with our provision of the Services you require;
- to third-party service providers, agents, professional advisors and other organisations we have engaged to perform any of the functions listed in the section above for us, as well as their respective representatives; and
- any other related legitimate business purposes.
Accuracy and Security of Personal Information
Where personal information is submitted by you on behalf of another person or concerns another person other than yourself, you represent and warrant to us that all the necessary consents procured in accordance with applicable law, for such purposes stated in the relevant sections of this Privacy Policy have been obtained from the relevant person(s) and that you have retained proof of these consents, such proof to be provided to us upon our request.
It is crucial that you update us of any changes or updates to your personal information. As such, we may from time to time do data verification exercises for you to provide us with any such updates.
We strive to protect the security of your information and are constantly reviewing and enhancing our information security measures. We take reasonable effort to implement appropriate administrative, technical, personnel, and physical measures (a) to safeguard personal information against loss, theft, unauthorised use, copying, disclosure, or modification; and (b) to ensure the integrity of the personal information, as encapsulated in our internal data protection rules and PDPA compliance policies. You should be aware, however, that no method of transmission over the Internet or method of electronic storage is 100% secure, in particular the transmission of data over open or public networks. Therefore, we recommend against transmitting any confidential or sensitive data over open or public networks.
In the unlikely event that we suffer a data breach in relation to personal information, we will assess whether the data breach is notifiable, and will attempt to notify the affected persons and/or the PDPC where it is assessed to be notifiable. To be clear, a data breach does not trigger any obligation to notify affected persons and/or the PDPC. For this purpose, a “data breach” in relation to personal information means (a) the unauthorised access, collection, use, disclosure, copying, modification or disposal of personal information; or (b) the loss of any storage medium or device on which personal information is stored in circumstances where the unauthorised access, collection, use, disclosure, copying, modification or disposal of the personal information is likely to occur.
Retention of Data
Any personal information in our possession or under control will be destroyed and/or anonymised when:
- the purpose for which the personal information was collected is no longer served by the retention of such personal information, including to address any complaints, as well as develop or improve our Services in line with feedback; and
- the retention is no longer necessary for any audit, legal, regulatory, or business purposes, including the maintenance of business records in accordance with record retention requirements under applicable law or for business analysis purposes, as well as make or defend against any legal claims.
Transfer of Personal Information to Other Countries
Some of the uses and disclosures mentioned in this Privacy Policy may involve the transfer and processing of your personal information, as data in transit or otherwise to and in various countries around the world that may have different levels of privacy protection than your country. By submitting your personal information, you consent to such transfers and processing. We take reasonable steps to ensure that appropriate levels of protection necessary to maintain the security and integrity of your personal information are in place and that any transferred data is processed only in accordance with the PDPA, the GDPR and any other applicable law. Specifically, we have or will have in place appropriate contractual and/or commercial agreements or arrangements to ensure that while under certain circumstances your personal information may be disclosed or transferred to countries which do not have requirements of data protection that is comparable to that under the PDPA, parties will abide by the requirements under applicable law. Where it is necessary for relevant third parties to further disclose personal data onward to other third parties, we will endeavour to ensure that these parties also abide by the PDPA or such applicable law.
Access, Correction and Withdrawal
The consent that you provide for the collection, use, disclosure and retention of all or any parts your personal information will remain valid until such time it is being withdrawn by you in writing.
You may request to access and/or correct the personal information currently in our possession or withdraw your consent for the collection, use, disclosure and/or retention of your personal information in our possession or under our control at any time by contacting us at [email protected]. Where appropriate, such request may be referred to the relevant data protection officer.
For a request to access, correct or update personal information, we will process your request within a reasonable amount of time from when the request is made.
While we will, in most instances, provide a copy of the requested information or make the requested correction or update, where we are unable to provide you with any records of personal information or to make a correction or update requested, we shall, where required under applicable law or otherwise appropriate, inform you of the reasons why we are unable to do so. Please note that depending on the request that is being made, we will only need to provide you with access to the personal information contained in the documents requested, and not to the entire documents themselves. In those cases, it may be appropriate for us to simply provide you with confirmation of the personal information that we have on record, if the record of your personal information forms a negligible part of the document.
We may also charge a reasonable fee for the handling and processing of your requests to access, correct and/or update your personal information. You will be notified in advance of such costs.
For a request to withdraw your consent to the processing of personal information, this will affect our ability to provide you with GE360 access and the use of its Services. We will therefore delete your GE360 account in such an event, which will be done within a reasonable amount of time from when the request is made.
Questions or Feedback
If you have any questions about this Privacy Policy or any other queries in relation to how we manage, protect and/or process your personal information, please contact us at [email protected]. Where appropriate, such request may be referred to the relevant data protection officer.
Updates
This Privacy Policy may be updated from time to time without any prior notice. As changes to this Privacy Policy take effect when they are posted on GE360, you may determine if any such revision has taken place by referring to the date on which this Privacy Policy was last updated and should visit this website periodically to note any changes. Your continued use of any Service, including without limitation GE360 itself, constitutes your acknowledgement and acceptance of such changes.
Last Updated 19 March 2024
